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Update on LPFM Rules
When we last discussed LPFM facilities, the primary focus was on the elimination of the third adjacent protection requirements to full-service facilities. Now almost two years later and a couple of translator articles in between, we find that LPFM and translators are inextricably linked. The connection between these two services is a result of the necessary implementation of certain provisions of the Local Community Radio Act of 2010 (LCRA). I have always likened the FM allocation situation somewhat akin to the movement of electrons and "holes" in a semiconductor, and it is an undeniable fact that the demand for limited spectrum space has certainly decreased the number of "holes" in the substrate.
The first big ticket item in the LCRA, signed into law by the president in January 2011, is the removal of the third-adjacent protection requirements. The elimination of the third-adjacent requirement is a fairly simple concept, and is one that has been bantered about for many years, but was finally changed. In a nutshell LPFM applicants and licensees will no longer be required to maintain the third-adjacent spacing requirements to other LPFM, full-service FM, FM translator, and FM booster stations. There is a caveat to that provision, however.
Facilities that provide radio reading services via subcarrier must continue to be protected. When the LPFM service was established in 2000, the Commission did not implement additional provisions to reading services facilities reasoning that the subcarrier was transmitted within the assigned frequency, and was therefore receiving the same protection received by the main broadcast station. Shortly thereafter this decision was reconsidered due to concerns about the greater vulnerability of the specialized service receivers to third adjacent interference. Their designs caused them to be somewhat more susceptible to such interference than general consumer radios. Because of this, and the valuable service provided, the LCRA maintains the existing spacing table to facilities broadcasting reading services.
The other big item of note was the requirement ensuring the availability of spectrum for LPFM stations. The broad provisions of the act require that the Commission, when licensing translators, boosters, and LPFM stations. ensures that licenses are available for all three services, that the licensing decisions made are based on local community needs, and that all three services will remain equal in status and secondary to existing and modified full-service FM stations. The end result of this will ultimately be that a number of the pending translator applications from 2003 will have to be dismissed. Although the quantity to be dismissed will not be as large as it would have been had the ten-application cap been implemented, it still will likely be a fair number.
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